OSHA Inspection: ACH FOAM TECHNOLOGIES, LLC

Issued

Sep 23, 2008

Abate by

Nov 10, 2008

Penalty

Initial $5,000 · Current $2,500 Reduced

Hazardous substances E101

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not
furnish employment and a place of employment which were free from
recognized hazards that
were causing or likely to cause death or serious physical harm to
employees in that employees
were exposed to dust explosion, deflagration, or other fire hazard from
the improper design and
location of the air material separators:
a) The Murphy Rodgers WBSE-15-RAL dust collector for the wide-belt
sanders, near the
regrind/recycle area was located inside the building.
b) The "deduster" cyclone in the resin bag storage area used for
separating the air from the dust
collected at the Wieser Grinder was located inside the building.
c) The air exhausted from the Murphy-Rodger dust collector is discharged
directly into the work
area. This is specifically prohibited for hybrid mixtures.
d) The Murphy-Rodgers dust collector and the "deduster" cyclone inlet are
not provided with
isolation devices to prevent deflagration propagation from the air
material separator i.e. dust
collector and cyclone, upstream into the work area.
Among other methods, a feasible abatement methods to correct this hazard
is:
Perform a process hazard analysis (PHA) of the processes and the facility
per the intent of
NFPA 654 section 4.2 2006 standard for the Prevention of Fire and Dust
Explosions from the
Manufacturing, Processing and Handling of Combustible Particulate Solids.
Relocate the dust collector and the cyclone outside the building or
install  engineering controls
such as suppression, inerting, venting to the outside in accordance with
the requirements of
National Fire Protection Association (NFPA) 654, Standard for the
Prevention of Fire and Dust
Explosions from the Manufacturing, Processing, and Handling of Combustible
Particulate Solids
section 7.13.1.1.1.
Discharge the exhausted air from the Murphy Rodgers dust collector to the
outside and install
isolation devices to prevent deflagration propagation upstream into the
work
area in accordance
with NFPA 654 section 6.1.3.1 &  section 7.1.5.1. and Section 2.6.1 of the
2002 FM Global
Property Loss Prevention Data Sheets 7-76 titled Prevention and Mitigation
for Combustible
Dust Explosions and Fires.
In accordance with 29 CFR 1903.19(d), abatement certification is required
for this violation
(using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in
addition, documentation demonstrating that abatement is complete must be
included with
your certification.  This documentation may include, but is not limited
to, evidence of the
purchase or repair of the equipment, photographic or video evidence of
abatement, or other
written records.

Issued

Sep 23, 2008

Abate by

Nov 10, 2008

Penalty

Initial $5,000 · Current $2,500 Reduced

Hazardous substances E101

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not
furnish employment and a place of employment which were free from
recognized hazards that
were causing or likely to cause death or serious physical harm to
employees in that employees
were exposed to dust explosion, deflagration, or other fire hazard in that
there
were there were
ignition sources in areas combustible dust was processed.
ACH Foam Technologies, LLC- The employer did not ensure that the there
were no open flame
ignition sources in the facility associated with environmental or comfort
heating system and that
combustion air was ducted from outside the building in areas where
combustible dust was
processed.
a) The horizontal-flow furnace in the mezzanine storage area above the
lunch room has a
standing pilot flame; the furnace is not equipped with a sealed combustion
chamber where
combustion air is ducted to the furnace from outside.
b) The unit heaters hung from the roof trusses through out the facility,
had a standing pilot, and
were not equipped with sealed combustion chamber.
c) The 50, 000 cfm Hastings make-up air unit, mounted on a platform under
the roof deck is
a direct fired, natural gas unit without heat exchangers or sealed
combustion and has a pilot
flame. The direct fired combustion unit directly fires into the supply air
path entering the
building.
Among other methods, a feasible abatement method to correct this hazard
is:
Perform a process hazard analysis (PHA) of the processes and the facility
per the intent of
NFPA 654 section 4.2 2006 standard for the Prevention of Fire and Dust
Explosions from the
Manufacturing, Processing and Handling of Combustible Particulate Solids.
Replace the direct fired unit with one that is fired by indirect means.
Replace the horizontal furnace and the heating units  with one equipped
with a sealed combustion
chamber which entrain outside air for combustion.
In accordance with 29 CFR 1903.19(d), abatement certification is required
for this violation
(using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in
addition, documentation demonstrating that abatement is complete must be
included with
your certification.  This documentation may include, but is not limited
to, evidence of the
purchase or repair of the equipment, photographic or video evidence of
abatement, or other
written records.

Issued

Sep 23, 2008

Abate by

Sep 26, 2008

Penalty

Initial $3,500 · Current $1,750 Reduced

Issued

Sep 23, 2008

Abate by

Nov 10, 2008

Issued

Sep 23, 2008

Abate by

Sep 26, 2008

Penalty

Initial $3,500 · Current $1,750 Reduced

Issued

Sep 23, 2008

Abate by

Nov 10, 2008

Penalty

Initial $1,500 · Current $750 Reduced

Hazardous substances 1797

Issued

Sep 23, 2008

Abate by

Sep 26, 2008

Penalty

Initial $3,500 · Current $1,750 Reduced

Issued

Sep 23, 2008

Abate by

Nov 10, 2008

Penalty

Initial $5,000 · Current $2,500 Reduced

Hazardous substances E101

Issued

Sep 23, 2008

Abate by

Nov 10, 2008

Penalty

Initial $1,500 · Current $750 Reduced

Hazardous substances 1990E200

Issued

Sep 23, 2008

Abate by

Nov 10, 2008

Penalty

Initial $5,000 · Current $2,500 Reduced

Hazardous substances E101

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not
furnish employment and a place of employment which were free from
recognized hazards that
were causing or likely to cause death or serious physical harm to
employees in that employees
were exposed to dust explosion, deflagration or other fire hazard due to
the building not being
protected from a dust deflagration hazard:
a) ACH Foam Technologies, LLC- The employer did not ensure that when a
dust deflagration
hazard existed, the process and facility were protected from its effects
by segregation, separation
or detachment; building construction and deflagration venting. All
processes, bulk storage of
resin, molding, cutting, regrinding, packaging and storage of finished
products in the building
were in the same general area. No deflagration vents were provided in the
building.
A dust sample taken from the polystyrene dust accumulated on a horizontal
surface of the
densifier indicated that the dust was Class II material with an explosion
severity of 1.95. A dust
sample taken from the dust accumulated on the floor in the mezzanine
storage area, above the
employee lunch room indicated that the dust was Class II material with an
explosion severity of
1.57.
Among other methods, a feasible abatement method to correct this hazard is:
Perform a process hazard analysis (PHA) of the processes and the facility
per NFPA 654 section
4.2 2006 standard for the Prevention of Fire and Dust Explosions from the
Manufacturing,
Processing and Handling of Combustible Particulate Solids.
Install protection systems such as the segregation of combustible dust
areas and deflagration
venting to a safe outside location to protect the facility and the
processes from dust deflagration
as specified in NFPA 654 section 6.1.1 and Section 2.3.3.1 of 2002 FM
Global Property Loss
Prevention Data Sheets 7-76 titled Prevention and Mitigation for
Combustible
Dust Explosions
and Fires.
In accordance with 29 CFR 1903.19(d), abatement certification is required
for this violation
(using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in
addition, documentation demonstrating that abatement is complete must be
included with
your certification.  This documentation may include, but is not limited
to, evidence of the
purchase or repair of the equipment, photographic or video evidence of
abatement, or other
written records.

Issued

Sep 23, 2008

Abate by

Nov 10, 2008

Penalty

Initial $5,000

Hazardous substances E101

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not
furnish employment and a place of employment which were free from
recognized hazards that
were causing or likely to cause death or serious physical harm to
employees in that employees
were exposed to dust explosion, deflagration, or other fire hazard because
the combustible dust
was not  kept to a minimum by both capturing it at the point of generation
and minimizing
escape of fugitive combustible dust. Cleaning was performed in a manner
which generated dust
clouds:
a) No local exhaust ventilation is provided to capture the dust generated
by the regrind and
densifying operations.
b) Portable centrifugal fans are used to convey product to the storage
bags which pressurize the
bags and exacerbate the leakage of dust from the bags.
c) Product conveying ducts that are under positive pressure leak at the
quick disconnect
connections. Plastic tape is used as a fix in several areas at
quick-disconnect connections of the
ducts to prevent leakage of dust.
d) Compressed air is used to clean dust in the regrind/recycle area and
the sanding area with
pressure exceeding 15 psi and without removing or shutting down electrical
equipment or other
ignition sources not suitable for Class II locations.
e) The abandoned 20 ft. long flex duct attached to the cyclone was full of
styrene dust.
Among other methods, a feasible abatement method to correct this hazard
is:
Perform a process hazard analysis (PHA) of the processes and the facility
per NFPA 654 section
4.2 2006 standard for the Prevention of Fire and Dust Explosions from the
Manufacturing,
Processing and Handling of Combustible Particulate Solids.
Minimize the escape of fugitive dust by providing exhaust ventilation for
the grinder and
densifier; m as per Section 8.1.1 of NFPA 654 and per Section 2.3.4.3 of
2002 FM Global
Property Loss Prevention Data Sheets 7-76 titled Prevention and Mitigation
for Combustible
Dust Explosions and Fires .
Only use compressed air to clean areas that has air pressure reduced to 15
psi, and only after
all electrical equipment not suitable for Class II locations & ignition
sources have been removed
or shut down as specified by Section 8.2.2.2 of NFPA 654.
Convey the product to the fabric silos (storage bags) without pressurizing
them; maintain and
operate equipment in a manner that minimizes the escape of dust as per
Section 8.2.1.1 of
NFPA 654 and Section 2.3.4.3 of 2002 FM Global Property Loss Prevention
Data Sheets 7-76
titled Prevention and Mitigation for Combustible Dust Explosions and Fires
Do not disconnect branch lines or blank off unused portions of the
pneumatic conveying system
to maintain the required airflow as per NFPA 654, Section 7.3.2.2 and 2002
FM Global
Property Loss Prevention data sheets, Section 2.6.2.2.
In accordance with 29 CFR 1903.19(d), abatement certification is required
for this violation
(using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in
addition, documentation demonstrating that abatement is complete must be
included with
your certification.  This documentation may include, but is not limited
to,
evidence of the
purchase or repair of the equipment, photographic or video evidence of
abatement, or other
written records.

Issued

Sep 23, 2008

Abate by

Nov 10, 2008

Penalty

Initial $5,000 · Current $2,500 Reduced

Hazardous substances E101

Issued

Sep 23, 2008

Abate by

Nov 10, 2008

Penalty

Initial $5,000

Hazardous substances E101

Issued

Sep 23, 2008

Abate by

Nov 10, 2008

Penalty

Initial $5,000 · Current $2,500 Reduced

Hazardous substances E101

Issued

Sep 23, 2008

Abate by

Nov 10, 2008

Penalty

Initial $5,000

Hazardous substances E101

Issued

Sep 23, 2008

Abate by

Nov 10, 2008

Penalty

Initial $1,000 · Current $500 Reduced

Hazardous substances 8111

Issued

Sep 23, 2008

Abate by

Sep 26, 2008

Hazardous substances 9135